Your Privacy Matters: 202 pub is committed to protecting your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. By using the 202 pub platform, you consent to the practices described in this Privacy Policy.
1Data Controller
For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173) and all applicable data protection legislation, the data controller responsible for your personal information is 202 pub, the operator of the online gaming platform accessible at 202pub.org and all associated subdomains and mobile interfaces (collectively, the "Platform").
As data controller, 202 pub determines the purposes and means by which your personal data is processed. If you have any questions or concerns about how 202 pub handles your personal data, please refer to Section 13 (Contact Us) of this Privacy Policy.
2Data We Collect
202 pub collects personal data from you in the following categories:
- Identity Data: Full legal name, date of birth, nationality, and government-issued identification details (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS ID).
- Contact Data: Philippine mobile number, email address, and residential address.
- Financial Data: GCash account details, PayMaya / Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals. Note: 202 pub does not store full card numbers; payment data is tokenised by our payment processors.
- Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings (deposit limits, self-exclusion status).
- Transaction Data: Records of all deposits, withdrawals, wagers, game results, bonus claims, and promotional activity on your 202 pub account.
- Technical Data: IP address, device type, operating system, browser type and version, time zone, and session data collected automatically when you access the Platform.
- Usage Data: Information about how you navigate and interact with the 202 pub Platform, including pages visited, games played, session duration, and click-stream data.
- Communications Data: Records of your interactions with 202 pub customer support, including live chat transcripts and email correspondence.
- Verification Data: Documents and information submitted as part of the Know Your Customer (KYC) verification process, including copies of identification documents and proof of address.
202 pub collects this data directly from you (during registration, KYC, and account use), automatically (through cookies and technical tracking), and from third parties (such as payment processors and identity verification service providers).
3How We Use Your Data
202 pub uses your personal data for the following purposes:
- Account Management: To create, maintain, and administer your 202 pub player account, including processing your 202 pub Login credentials and account preferences.
- Service Delivery: To provide you with access to the full range of 202 pub games, promotions, and platform features.
- Payment Processing: To process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records of all transactions.
- Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine anti-money laundering regulations.
- Regulatory Compliance: To comply with obligations under the Anti-Money Laundering Act (RA 9160), PAGCOR regulations, the Data Privacy Act (RA 10173), and other applicable Philippine laws.
- Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
- Responsible Gaming: To administer responsible gaming tools including deposit limits, session reminders, and self-exclusion, and to identify players who may be at risk of problem gambling.
- Customer Support: To respond to your enquiries, complaints, and support requests in a timely and effective manner.
- Marketing & Promotions: To send you information about 202 pub promotions, bonuses, and new features, where you have consented to receive such communications. You may withdraw this consent at any time.
- Platform Improvement: To analyse usage patterns and technical data to improve the performance, security, and user experience of the 202 pub Platform.
4Legal Basis for Processing
202 pub processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:
- Contractual Necessity: Processing is necessary to perform the contract between you and 202 pub — specifically, to operate your player account, process transactions, and deliver gaming services.
- Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act.
- Legitimate Interests: Processing is necessary for 202 pub's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
- Consent: For marketing communications and certain non-essential cookies, 202 pub relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
5Sharing Your Personal Data
202 pub does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:
- Payment Processors: GCash (Mynt – Globe Fintech Innovations), PayMaya / Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
- Identity Verification Providers: Third-party KYC and age verification service providers engaged to assist with PAGCOR-mandated identity verification requirements.
- Game Software Providers: Licensed game developers and live dealer studios whose games are hosted on the 202 pub Platform, to the extent necessary for game operation and dispute resolution.
- Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory directive.
- Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or is necessary to prevent or investigate criminal activity.
- IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged to support the operation and security of the 202 pub Platform.
All third-party service providers engaged by 202 pub are required to process personal data only in accordance with 202 pub's instructions and applicable data protection law.
6Data Retention
202 pub retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
In general, 202 pub retains player account data and transaction records for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act. KYC verification documents are retained for the same minimum period.
Where personal data is no longer required for any lawful purpose, 202 pub will securely delete or anonymise it in accordance with its internal data retention and disposal procedures.
7Security Measures
202 pub implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:
- 256-bit SSL/TLS Encryption: All data transmitted between your device and the 202 pub Platform is encrypted using industry-standard SSL/TLS protocols.
- Password Hashing: Account passwords are stored using strong cryptographic hashing algorithms. 202 pub staff cannot view your password in plain text.
- Access Controls: Access to personal data within 202 pub is restricted to authorised personnel on a strict need-to-know basis, with role-based access controls enforced.
- Intrusion Detection: The 202 pub Platform is monitored continuously for suspicious activity, unauthorised access attempts, and potential security incidents.
- Regular Security Audits: 202 pub conducts regular security assessments and penetration testing to identify and remediate vulnerabilities.
While 202 pub takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 202 pub Login credentials and for notifying 202 pub immediately if you suspect any unauthorised access to your account.
8Cookies & Tracking Technologies
202 pub uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. A cookie is a small text file placed on your device when you visit the Platform.
- Essential Cookies: Required for the Platform to function correctly, including maintaining your login session and security tokens. These cannot be disabled.
- Functional Cookies: Remember your preferences such as language settings, game display options, and responsible gaming limits.
- Analytics Cookies: Collect anonymised data about how players navigate the Platform, helping 202 pub improve performance and user experience.
- Marketing Cookies: Used to deliver relevant promotional content to you, where you have consented to receive marketing communications.
You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair the functionality of the 202 pub Platform, including your ability to log in and play games.
9Your Data Privacy Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 202 pub:
- Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed — which is the purpose of this Privacy Policy.
- Right of Access: You have the right to request a copy of the personal data that 202 pub holds about you, along with information about how it is being processed.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 202 pub.
- Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 202 pub's legal retention obligations.
- Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 202 pub has violated your data privacy rights.
To exercise any of these rights, please contact the 202 pub Data Privacy Officer at [email protected]. 202 pub will respond to all verified requests within 15 business days in accordance with NPC guidelines.
10Minors & Age Restriction
The 202 pub Platform is strictly intended for persons aged 21 years and above. 202 pub does not knowingly collect personal data from individuals under the age of 21. If 202 pub becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.
If you are a parent or guardian and believe that a minor has registered on the 202 pub Platform using your details or their own, please contact 202 pub support immediately at [email protected].
11Cross-Border Data Transfers
202 pub primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting or game software providers — 202 pub ensures that such transfers are carried out in compliance with the Data Privacy Act of 2012 and NPC regulations, including the use of appropriate contractual safeguards.
202 pub will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.
12Changes to This Privacy Policy
202 pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least 7 days before the changes take effect.
The "Last updated" date at the top of this Privacy Policy indicates when the most recent revision was made. Your continued use of the 202 pub Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.